Answer · Recordkeeping

Can someone else submit my OSHA data for me?

1 min read Checked against current CFR text Sep 2026 Reviewed by Renae Irek
Short answer

Yes. Just as a third party is allowed to maintain an employer's injury and illness records, a third party is allowed to submit the data for that employer.

What does not transfer is the obligation: the employer remains responsible for the records being accurate and filed on time.

29 CFR 1904.41 Read it on osha.gov.

Delegating the work is not delegating the duty

This is the distinction worth holding on to. A consultant, a staffing partner or a software provider can prepare and file the submission. If it is late or wrong, it is still the employer's late or wrong submission.

What to keep if somebody files for you

Confirmation of what was submitted, for which establishments, on what date. If the person who filed leaves the arrangement, that record is the only proof the year was filed at all.

Safety Sherpa is software, not a safety consultancy. This page quotes the cited regulation and links to the source text so you can read it yourself. It is not legal advice and does not replace a qualified person's judgment about a genuinely unclear case — our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make.